Augustus v. Greene County Adult Probation Dept., 3:22-cv-00363

Plaintiff Anthony Augustus, a pro se detainee at Greene County Adult Detention Center, sued Greene County Adult Probation Department, Greene County Adult Common Pleas Court, and probation officer Josh Mixon alleging Mixon told plaintiff's wife Augustus "was lying 90% of the time," causing marital strain and emotional distress.
Claims asserted: defamation (slander/libel) and damages for pain, suffering, mental anguish; plaintiff seeks monetary relief and was granted in forma pauperis status.
The court conducted sua sponte screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b) to determine frivolity, immunity, or failure to state a claim.
Court found no diversity jurisdiction: plaintiff and defendants are Ohio citizens; no complete diversity alleged.
Court found no federal-question § 1983 claim: no federal statute or constitutional deprivation pled; defamation is a state tort and plaintiff did not allege the required "stigma-plus" (reputational injury plus deprivation of a separate liberty or property interest).
Court also concluded Greene County Adult Probation Department and the Common Pleas Court are not suable "persons" under § 1983 (and courts are not sui juris under Ohio law), and recommended dismissal with prejudice and denial of leave to appeal IFP.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction — diversity	Augustus seeks relief but does not assert federal claims; diversity exists?	Defendants / record show all parties are Ohio citizens so no complete diversity.	Dismiss for lack of diversity jurisdiction; § 1332 does not apply.
Federal-question jurisdiction / § 1983 viability	Mixon's statements to plaintiff's wife constitute actionable constitutional wrong (defamation) under § 1983.	Defamation is state law; no allegation of deprivation of liberty/property to satisfy due-process stigma-plus.	§ 1331 not invoked; defamation alone cannot sustain a § 1983 claim—claim fails.
Capacity / suability of county entities and court	Complaint names Probation Dept. and Common Pleas Court as defendants.	Ohio law: courts are not sui juris; probation department and a county entity not a "person" for § 1983 absent municipal policy/custom allegations.	Claims against Greene County Adult Probation Department and Greene County Common Pleas Court dismissed.
Supplemental jurisdiction and relief disposition	Plaintiff seeks state-law damages for defamation.	Court may exercise supplemental jurisdiction but typically declines if federal claims are dismissed.	Recommended dismissal of state-law claims without exercising supplemental jurisdiction; case dismissed with prejudice and IFP appeal denied.

Denton v. Hernandez, 504 U.S. 25 (1992) (in forma pauperis screening to deter frivolous claims)
Neitzke v. Williams, 490 U.S. 319 (1989) (standards for dismissing frivolous pro se claims)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading requirements for plausible claims)
Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (applying Rule 12(b)(6) standards to § 1915 screening)
Paul v. Davis, 424 U.S. 693 (1976) (defamation alone is not a constitutional deprivation; stigma-plus requirement)
Doe v. Mich. Dep’t of State Police, 490 F.3d 491 (6th Cir. 2007) (explaining stigma-plus test for due process claims)
Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978) (municipal liability requires policy or custom causing constitutional violation)
Siegert v. Gilley, 500 U.S. 226 (1991) (defamation is a state-law tort, not per se a constitutional injury)
Malone v. Court of Common Pleas of Cuyahoga County, 45 Ohio St.2d 245 (1976) (Ohio courts are not sui juris)
McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997) (standards for denying leave to appeal IFP)